In order to strengthen the regulation of cosmetics and safeguard consumer rights, the NMPA's Department of Cosmetics Supervision has provided answers to key industry concerns, such as labeling based on current Chinese laws and technical standards. CIRS Group has compiled the information and translated it into English for your reference.
Q1: What are the labeling requirements for allergens introduced through ingredients such as fragrances and botanical extracts in the Chinese labeling of cosmetics?
A: Cosmetic ingredients such as fragrances and botanical extracts may introduce allergenic substances into the product. These allergenic components should be labeled in accordance with the following guidelines:
For allergens introduced via fragrances, according to the Provisions for the Provisions on the Management of Cosmetic Registration and Filing Data, there are two acceptable methods for listing fragrance ingredients in the product formulation:
- If only “fragrance” is listed in the product formulation table, the specific components and concentrations of the fragrance do not need to be submitted. However, if the product label identifies specific fragrance components, or if the original packaging of imported products lists specific fragrance ingredients, this must be explained in the remarks column of the formulation table.
- If both “fragrance” and the specific components of the fragrance are listed in the product formulation table, the manufacturer of the fragrance must provide documentation detailing all fragrance components and their respective concentrations.
In accordance with the above provisions, if the registered or notified product formulation lists only “fragrance,” then “fragrance” alone may be indicated in the “Ingredients” section of the label. However, if allergenic substances are required to be labeled under Chinese regulations or the regulations of the exporting country (e.g., Technical Guidelines for Children's Cosmetics), they must be individually listed in the “Safety Warning” section of the Chinese label.
If the formulation includes both “fragrance” and specific fragrance components, then both “fragrance” and its specific components must be listed in the “Ingredients” section of the label. For allergens introduced through botanical extracts or other ingredients, labeling can be conducted with reference to the above guidelines.
Q2: What are the labeling requirements when multiple general cosmetics that have completed notification are sold in a gift/boxed set?
A: Article 35 of the Measures for the Supervision and Administration of Cosmetics Production and Operation stipulates that the smallest sales unit of a cosmetic product must bear a Chinese label. The label content must be consistent with the product label sample submitted during product registration or notification.
According to Article 32 of the Provisions on the Management of Cosmetic Registration and Filing Data, for registered or notified products that are sold as a set (e.g., in gift boxes or combination packaging), if the combination process does not involve direct contact with the product contents, and if the only addition is the name of the combination packaging while all other labeling content does not exceed the scope of each individual product’s label, and the labeling information on the combination packaging fully covers the labeling information of each inner product, then it is not necessary to re-upload label images for the combination packaging during registration or notification.
Q3: Do products labeled as “microcrystalline” or “microneedle” fall within the definition of cosmetics?
A: According to the Cosmetics Supervision and Administration Regulations, cosmetics are daily chemical products intended to be applied to the surface of the human body-such as the skin, hair, nails, and lips.
If a product labeled as “microcrystalline” or “microneedle” is determined-based on its formulation, method of use, and physical form of the product contents - not to be applied to the surface of the human body, then such a product falls outside the definition of cosmetics as stipulated in the Cosmetics Supervision and Administration Regulations.
About CIRS
The CIRS cosmetic team is dedicated to ensuring that cosmetic products meet stringent global regulatory standards. It can provide one-stop services covering the whole life-cycle of a personal care product, which includes cosmetic ingredient development, physical/chemical tests, toxicological tests (in vivo & in vitro), efficacy studies (in vivo & in vitro), ingredient registration, and product registration.
Cosmetic services in China:
- China Cosmetic Registration and Filing;
- China New Cosmetic Ingredient Registration and Filing;
- China Cosmetic Ingredient Quality and Safety Information Code Application (NMPA Code);
- China Cosmetics Safety and Efficacy Test;
- China Cosmetic Safety Assessment Report;
- China Toothpaste Filing;
- China Disinfectant Notification; and
- China Cosmetic Formula/Label/Claim Review
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
Further Information
https://www.nmpa.gov.cn/xxgk/zhcjd/zhcjdhzhp/20250617153950104.html
